AUDITING ELECTRONIC GAS MEASUREMENT PER API CHAPTER 21.
Keith Fry
Quorum Business Solutions, Inc.
1420 West Mockingbird Land, Suite 700
Dallas, TX 75247
INTRODUCTION
Auditing evolved as a business practice as owners began
to realize a standardized form of accounting must exist to
prevent fraud. Financial audits made their way into
businesses during the late 1700s. The industrial
revolution brought about the separation of job duties
beyond what a sole proprietor or family could oversee.
Managers were hired to supervise the employees and the
business processes. Businesses began to expand
geographically where previously they were all local.
Owners, who could not be in more than one place at a
time or chose to be absent, found an increasing need to
monitor the accuracy of the financial activities of their
growing businesses. Owners responded by hiring people
to check their financial results for accuracy, resulting in
the process of financial auditing. In the early 1900s and
at the request of the Securities and Exchange
Commission, the auditors’ reports of duties and findings
were standardized. Financial auditors developed methods
of reporting on selected key business cases as an
affordable alternative to examining every detailed
transaction. It was found with auditing that the evaluation
of both financial risk and financial opportunity was
improved.
The fingers of the financial audit began to reach into other
areas of business operations. Owners became interested
in the integrity of the financial transactions and began to
look at the values used to generate them. Business
owners began to understand that not only are the numbers
important, the neutrality and consistency of their
derivation is important as well. This most recent wave of
fraud protection in auditing practices culminated in the
Sarbanes-Oxley Act of 2002 (SOX).
Decades prior to SOX, the auditing process reached into
gas measurement. Auditing of gas measurement is
particularly relevant because gas measurement can be
directly tied to the monetary value of natural gas through
both the quality and the quantity of the gas. However, the
gas measurement process is made complex because the
commodity is hazardous, invisible, compressible, and
measurement is often made inferentially.
Advances in technology throughout the last half of the
20th century led us from the pneumatic / analog age to the
electronic / digital age. While these advances allowed the
industry to improve the accuracy of gas measurement,
they also brought additional complexity. Managers and
owners still needed assurances of the integrity of their
measurement processes. The industry’s response was to
standardize the electronic gas measurement process,
resulting in the American Petroleum Institute’s Manual of
Petroleum Measurement Standards Chapter 21.1 – Flow
Measurement Using Electronic Metering Systems (API
21.1). This standard provides the framework for auditing
electronic gas measurement systems.
American Petroleum Institute’s Manual of Petroleum
Measurement Standards Chapter 21.1 – Flow
Measurement Using Electronic Metering Systems (API
21.1)
API 21.1 is an international standard which describes the
minimum specifications for gas measurement systems of
hydrocarbon and other related gases. It attempts to
practically minimize the uncertainties associated with
electronic gas measurement. It applies to both production
and custody transfer applications using industry-
recognized primary measurement devices.
There is a great deal of information contained in the API
21.1 standard and it has proved vital to ensure the
integrity of electronic gas measurement. One of the
topics covered within API 21.1 is a description of an
electronic gas measurement system, including its various
components, the algorithms necessary for adequate
calculation, specifications for equipment installation and
commissioning, and data security requirements. The
standard also describes the minimum necessary data to be
made available in order to allow for a thorough audit of
the system. Of particular interest to the auditor is Section
1.6 - Audit and Reporting Requirements. The gas
measurement audit process should consider all aspects of
this standard as it details at great length the necessary
steps for a thorough, complete audit; much of which is
touched upon in this paper.
Audit Programs
The process of auditing can be looked at from many
different perspectives and approached in various ways
and with differing objectives. The same questions that
apply to any business process need to be asked as part of
developing a formal audit program within the company.
Why do we need to audit electronic gas measurement? In
a word: Economics. The benefits of electronic gas
measurement audits have been proven to justify the costs.
However, prudence should be used in focusing audit
resources. Valuable lessons can be learned from the
financial accounting profession. Just as they migrated
from verifying every transaction to developing a reporting
system on selected key business cases, the gas
measurement auditing process should develop selected
key measurements to audit.
Redundancy, used wisely, can be an extremely effective
way to focus audit resources. Some redundancy should
be built into the business processes of all natural gas
companies. The two most common uses of redundancy in
gas measurement are balances and check meters.
Balances compare volumes, energy and / or mass going
into a system against what goes out. The measurements
going into the system should match the measurements
going out within an uncertainty tolerance. Differences
outside the tolerance can help to isolate measurement
problems and point to where audit resources can be
applied. A system strategically segmented will aid in this
process. A good enterprise measurement system will
calculate the balance indifferences automatically.
Check meters measure the same gas as another meter,
usually a custody transfer meter. Ideally, a check meter
has separate, matching primary devices. However, it is
not uncommon to see shared primary devices, with
separate (check) orifice taps and / or secondary and
tertiary devices. Check meters are not only the best form
of gas measurement redundancy - they are the definition.
They are invaluable when failures occur at critical
stations. Besides failures, some types of measurement
errors cannot be compensated for mathematically, such as
damaged or reversed orifice plates. Check meters allow
for accurate replacement of missing or erroneous
measurements and can carry tremendous weight in audit
adjustment negotiations.
Key process indicators (KPIs) are another means of
focusing audit resources. Certain metrics apply to the
healthy operation of a business. Gas measurements that
can be directly associated to those key process indicators
are good candidates for audits. Beyond KPIs, just as in
the financial profession, Key Risk Indicators (KRIs) can
be developed which help the business know when and
where to expand audits. KRIs are metrics which apply to
changes in the industry or the company’s environment
which have shown to be related to measurement errors.
An effective audit program will also include random
audits. The cost effectiveness of these random audits is
enhanced with a risk-based approach by varying
frequency, scope and depth of evidence required. Risk
assessment should include total energy measurement, past
compliance, and the cost of the audit. Revenue recovered
is not the only justification for the cost of an audit. The
potential revenue not lost must also be considered, which
is hard to quantify. There is a lot of good to be said about
accountability. Most people perform better when they
know someone may be watching.
Once the decisions have been made regarding the value of
the audit, then other decisions become easier to make.
The focus of the audit can be narrowed with a discussion
of objective, scope and expertise.
Audit Objective and Scope
Before determining who should do the audit, it is best to
define the objective and the scope. The objective makes
clear to all involved what the purpose of the audit is. The
scope of the audit is the range of activities and the periods
of records that are to be subjected to examination.
The objective should always include an unbiased
examination and evaluation of the electronic gas
measurement. However, the objective will also help to
determine the scope of the audit and the best approach to
take in conducting the audit. For example, if the purpose
of the audit is to confirm pressure bases used in volume
calculations match contractual obligations, an internal
audit may achieve this objective. On the other hand, if
the purpose of the audit is to support legal action, an
external audit by a reputable third party may be necessary.
If the purpose of the audit is to help minimize the risk of
errors in reporting critical data, then certain policies and
procedures will need to be confirmed. Defining the
objective of the audit provides the landscape for defining
the scope.
Scope determines the breadth and depth of the audit and
defines what material, equipment, information, processes,
time periods and business departments / entities will be
examined. Scoping will define what documents need to
be reviewed. These documents will likely include
contracts, volume logs, meter configuration logs, event
logs, meter inspection and testing reports, meter
installation and change reports, and gas quality reports.
However, depending on the scope of the audit, other
documents may be required. If the scope of the audit
includes examination of compliance with procedures, then
policies and procedures will have to be studied and
understood as well as any supporting documents that are
referenced by the policies and procedures. If the scope
includes the calibration of instruments, certification
documents that reference the calibration device back to a
standard, such as NIST may be required. A well-defined
scope sets the stage for how the audit is conducted.
Audits vs. Reviews
Just like in financial audits, there is a difference between
a review and an audit. Audits provide a reasonable basis
for expressing an opinion regarding the gas measurement
process as a whole. Reviews do not provide the same
basis, because they are not concerned with internal
control structure; risk control assessment; tests of
measurement data; or corroborating evidence via
validation, observation or physical inspection. A review
may include some of these elements, though.
In the gas measurement world a review is almost always
referred to as an audit. It is just an audit with a smaller
scope. It confirms the documentation for a certain meter
matches with its final quantity transaction records. These
reviews are sometimes called office audits or
administrative audits. These reviews can be very
valuable, and they are much less costly than a fully-
scoped audit. Sometimes they discover significant errors,
while other times the review provides direction for an
examination to be expanded. As questionable areas arise
during the review, the scope can be expanded to
investigate certain parts of the review in more detail.
Reviews can be done in the field, too. Depending on the
scope, this is often called witnessing or field auditing.
The practice involves confirming that the data from the
electronic gas measurement (EGM) device matches the
conditions, settings and sizes actually in use. This
expands the scope significantly to include observation,
physical inspection, and validity tests of the operation of
the equipment. Reviewing only documentation in the
office does not mean the equipment and quality tests were
performed properly or in the right sequence. For
example, some multi-variable instruments require the
differential pressure to be verified before the static
pressure is calibrated. Is the sample pulled before or after
the meter tube is isolated to check the orifice in a single
chamber or flange union fitting? Are verification tests
performed at each of the set points after a field
calibration? The sequence of some tests does affect the
accuracy of the measurement.
As EGM devices replaced pneumatic devices and chart
recorders, field reviews became much more valuable.
Although the term “garbage in, garbage out” was coined
in the data processing office, it now applies equally as
well in the field. Much of the source of flow
measurement data and procedures must now be examined
in the field.
An EGM system audit would include the same things as
an office and field review. However, it would also
include any data or measurement from the primary
devices to the corrected quantity transaction records,
including how that data was derived, is normally derived,
and any supporting documentation. Audits pull in data
from regulations, tariffs, contracts, as well as standards
and the documents they may reference. Policies and
procedures would be examined for exposure to risk.
Included in the examination would be the flow device,
transducers / transmitters, and the flow calculations.
Primary, secondary, tertiary and auxiliary devices are
examined and tested, with supporting documentation. All
equipment testing should be comprehensive and fully
documented. Transmission, recalculation and storage of
the data are also verified and tested.
The Auditor
Knowing the objective and scope of the audit will help in
determining who should perform the audit. If the audit is
an office review of data, someone with a general
knowledge of gas measurement and some guidance may
be able to verify data was correctly applied to final
quantity transaction records. Field audits require more
expertise. Field auditors have to also understand how
instruments function and interact with each other and the
process. They require knowledge of the limitations of
various devices and the ability to recognize when those
limitations are being exceeded.
As the scope expands, so must the auditor’s knowledge.
Skills required may include auditing, engineering /
technical, and business management consulting skills.
For large, fully-scoped audits, a team of auditors may be
required with different members being well-versed in
different aspects of the audit.
The auditor should be aware of the prevailing regulations
and tariffs which apply to each of the particular
measurement(s) being audited. He or she should be very
knowledgeable of the industry standards and common
industry practices. It helps if the auditor has an
understanding of the equipment manufacturers’ hardware,
software, and operational specifications as well. Auditors
tend to lean upon their background as they diagnose
problems. So, it is preferable if the background of the
auditor matches the scope. However, auditors with a
solid foundation of technical skills can quickly gain
proficiency in equipment knowledge. Most likely they
will have to gain an understanding of the meter owner’s
measurement policies and procedures. Experience with
various companies’ policies and procedures can help in
finding holes in other policies and procedures. In
essence, it is good for the auditor to know the gas
measurement business forward and backwards. A references AGA Report No.’s 5, 7, and 8; API MPMS
thorough knowledge of how gas is measured
electronically provides a framework for the auditor to
quickly recognize undesirable practices.
Furthermore, the auditor should be able to act
independently and be unbiased. He or she should not be
in, or reasonably seen to be in, a position to be influenced
by or in conflict with any commercial interest, duty or
obligation. The auditor should not be currently or
recently employed or contracted by either of the parties in
a role which could be viewed as a conflict of interest.
The auditor should also maintain an attitude of
professional skepticism. He should be very critical of
everything, but be willing to suggest a compromise if a
win-win solution is unavailable or an equitable solution
would severely affect the viability of one of the parties.
Ideally, the relationship between the transacting parties
will remain beneficial and not adversarial. Usually errors
are the result of simple oversights or misunderstandings.
Disagreements between transacting parties with important
business relationships can be taken out of the auditor’s
hands. The auditor can always be called back when
expertise is required to gain understanding.
Gathering Data
Once the auditor is chosen, one of his or her first steps
will be to gather information. The auditor will want to be
aware of any regulatory requirements, such as those from
FERC, BLM or BOERME. It is important to understand
that regulatory requirements may supersede contractual
requirements in custody transfer situations.
Copies of contracts are to be acquired and scrutinized.
Contractual requirements can and should include very
important agreements, such as pressure and temperature
base conditions, measurement units, contract hour, and
the location of the transfer of the custody of the gas.
Contracts should be reviewed for references to industry
and internal standards and noted exceptions to those
standards. Sometimes references are made to the latest
edition of a standard, as standards are amended from time
to time. Other times, a specific dated standard is
referenced. Gas quality thresholds may be spelled out, as
well as how and when gas quality updates are handled.
Instrument calibration methods and frequency may be
defined. Any limitations on access to data for auditing
purposes may also be stipulated. Data retention and prior
period adjustment thresholds for amount and time should
be mentioned and are of particular interest to the auditor.
As noted above, standards may be referenced in the
contract. If not, their contents may still prevail. Industry
standards are generally accepted at the negotiating table
and in the courtroom. Different standards apply to
different areas of gas measurement and some standards
reference other standards. For example, API 21.1
Chapter 14.3, Parts 1 through 4; GPA 2261 and 2286; and
NFPA 70. When the next revision is released, it will
likely reflect the growth of the use of ultrasonic and
coriolis meters in gas measurement by referencing AGA
Report No.’s 9 and 11.
Of particular note in standards are the phrases “shall”,
“should”, “shall not”, and “should not”. “Shall” and
“shall not” indicate items which are required by the
standard. “Should” and “should not” reference preferred
items which are not necessarily required. Recently,
sections of standards are being identified as “normative”
or “informative.” Normative sections are required.
Informative sections are informational only and are not
required.
When requesting data, the auditor should make the
request in writing and be as specific as possible. The
amount of data requested depends on the scope of the
audit. When scoping is performed correctly, the
information to be requested becomes easier to define.
Information required for most audits include:
• Station Name
• Station Identification
• Station Location
• Meter Identification (if different from the
station)
• Production Dates (Beginning and Ending)
• Original (Raw) Data Files
o Periodic Volume Data Logs
o Meter Configuration Logs
o Event Logs
o Alarm Logs
• Meter Inspection and Test Reports (including the
report just prior and just subsequent to the audit
period)
• Gas Analysis Reports (including the report just
prior and just subsequent to the audit period)
• Final Volume and Energy Data
API 21.1 sets the minimum retention period of the audit
trail at two years. If there is reason to believe an error has
existed longer than two years, more data should be
requested. But, it may not be available.
The auditor may also request the following supporting
documentation:
• Contracts
 • Meter Installation and Facility Design Drawings
and Documentation
• Flow Diagrams
• Standard Measurement Operating Policies and
Procedures
• Meter Change Reports
• Audit Trail Information
• Witness Reports
• Check Station Reports
Tests should be specifically requested as well. Schedules
may need to be developed for interested parties’
representatives to all be present. Tests should be
performed on each part of the measurement system within
scope to ensure repeatable and reproducible performance.
Personnel are observed as they perform their normal
activities. Processes and sequences are documented.
When measurement information is transferred from one
location or machine to another, methods to insure data
integrity and security are verified.
Examining Information
When all of the information required for the audit has
been acquired, the information is examined. Information
comes from many different sources and merges together
in the form of the final quantity transaction record.
Actually, the examination process is usually begun as
each process or document is inspected. The auditor may
note items which are suspect and validate these later.
An auditor looks for conflicts in the terms of the
regulations, tariffs, contracts, standards, and procedures
(governing documents) against what is actually being
done. If a procedure conflicts with a contract, the terms
of the contract override the procedures. If a contract
conflicts with a regulation, the regulation will override the
contract or the measurement system may be required to
comply with both. Standards and common industry
practices play a role here, too. If the governing
documents are silent regarding standards, the standards
should be followed. If regulations and contracts are
silent, but procedures conflict with standards,
documentation as to why standards are not followed
should exist.
The auditor determines if the measurement system is
capable of complying with the terms of the governing
documents. If the measurement facility is not properly
designed, errors may result. If the instruments are not
capable of performing at the levels specified in the
contract, this is noted. Sometimes the instruments are
properly installed and maintained, but the process requires
different or additional equipment to perform
satisfactorily.
Common problems are associated with device sizing. For
example, if a separator is too small, liquids may spill over
into the gas line causing measurement errors. If a
pressure transducer is not sized properly, it can become
saturated and unable to measure beyond its upper limit. If
an orifice plate is too small, it may saturate the
differential transducer. If it is so small it is out of beta
ratio, it may add to uncertainty. If the upstream meter tube
is too short, elbows, pipe fittings, pinched valves,
strainers, reducers, or expanders can affect the velocity
profile and proper measurement.
Other times, equipment is not properly installed.
Excessive pressure drops upstream of the meter can cause
phase changes. Liquids can accumulate and flow into the
meter run. Hydrates can form. Reciprocating
compressors can cause pulsating flow and if too close to
the meter, distort measurement.

Equipment should operate within the specifications of the
manufacturer and any applicable standards, such as API
21.1 and NEC. Tests can be made for most of the
processes involved. Although some tests may be
possible, they may not always be feasible. An orifice
meter may not be flow tested, but if measurements can be
made to show it complies with API 14.3, it can reasonably
be assumed the calculated flow rate will be correct. Tests
can also be performed on the differential pressure, static
pressure and temperature transducers. Ideally, tests will
be made to confirm all values from their source to the
final quantity transaction record.
Tests can also be made on gas quality. The equipment
and procedures are reviewed for compliance with
regulations; contracts; and GPA-2166, 2145, 2261, and
2172. Gas samples should be obtained, prepared, and
analyzed according to these governing documents.
Samples should be obtained during normal flowing
conditions. Poorly cleaned sample cylinders, sampling
systems, and gas chromatograph inlet systems, as well as
improper purging, will cause analyses to be
misrepresented. Gravimetrically prepared gas standards
which are traceable to NIST standards can be analyzed as
an unknown gas, with the results compared to the
certificate of analysis. This is one of the best ways to
insure a lab or online gas chromatograph is performing
properly.
The auditor is concerned not only with the results of the
test, but also how the tests are performed. Tests should be
done accurately, completely and, where applicable, in the
proper order. Because good technicians work quickly and
auditors are taking notes, an auditor may ask to see a test
performed a second or even a third time.
Many of the errors found during audits are the result of
inadequate maintenance. Accumulation of water, debris,
salt, scale, sand, paraffin, treating chemicals, or
compressor oil in the primary and secondary devices
causes measurement errors. Under extreme conditions,
these can plug or even damage the primary device. This
buildup of solids and liquids should be removed during
routine maintenance and minimized where possible.
Leaks are also a problem and should be tested. Checks
are made for leaks in gauge lines and manifolds. Leaking
seal rings cause under-registered flow, while leaking
check valves can cause backflow which may not be
registered because of the no-flow cut-off.
Rare is the circumstance where an orifice plate is not
checked during an audit. Besides confirming its bore
diameter, the plate is checked for concentricity,
orientation, thickness, and flatness. The bore should have
no nicks or burrs and the bore edge should be sharp.
All of the information from the various sources should
come together to produce the final transaction record.
This begins with the original quantity transaction records.
The flow computer manufacturer’s software may be
required to view the original quantity transaction records
or generate an ASCII file to be imported into another
system for analysis. If ASCII files are supplied for the
audit, the auditor understands these may not be the
original quantity transaction records. The same applies
for daily records.
All edits to the original data should be traceable from the
original data to the final quantity transaction record(s).
Contract information can be matched to the meter
configuration log. Other components of the meter
configuration log should agree with the specifications of
the meter, the gas quality, and the calculation methods.
Events should be reviewed for parameter changes,
transducer verification, and calibration adjustments.
Alarms can sometimes shed light on failure and override
conditions (including no flow conditions), frequent out-
of-range readings, power and communications problems.
Meter configuration logs are reconciled to the final
transaction records, adjusted by events, valid edits, and
gas analyses.
Gas analyses play a big role in volumes. Gas
chromatography has replaced almost all physical testing
for density and heating value. For this reason,
representative component percentages are very important.
Not only must the analysis be representative, it must be
applied and applied correctly. Conversely,
misrepresentative samples should be discarded.
Statistical analysis of the component data can help to
determine which samples are not representative.
Statistical analysis can also be applied to other volume
data. As volume and analytical data resolution have
increased, statistical analysis of the data has become more
important. It can help the auditor focus on anomalies
instead of plowing through thousands to hundreds of
thousands of data records. It allows the auditor to analyze
the individual data records without losing precision from
summation and averaging. Statistical analysis can help
identify missing, corrupted, static, inconsistent, or
incorrect data. Along with graphical representations of
the data, it can help to identify when a problem existed or
began.
Data can become lost. Sometimes production month
closing constraints do not allow enough time for data to
get into the final volume records and they are closed with
the best available data. When the data later becomes
available, it does not get updated. Other times, records
can be lost during transmission or accidentally deleted.
Charging system, battery, device, and circuit board
failures can cause measurements to be lost. If a missing
record cannot be produced, check meters are the best
means of reconstructing missing transactions. If a check
meter is not available and the contract does not speak to
the issue, an equitable method of estimation can be used
to determine the adjustment.
If adjustments to previously calculated volumes were
made for errors found prior to the audit, the period and
amount of the adjustment should be confirmed.
Adjustment periods which extend beyond the scope of the
audit should prompt an automatic extension of the audit
through the adjustment period.
If the auditor sees that all the data is present, the flow
computer is properly configured, the events correspond
with physical changes, and the gas analyses were properly
applied, there may still be differences to be resolved.
Errors can occur in the calculation of the final transaction
record if the proper volume calculation, equation of state,
or energy calculation is not used. While allowing for
calculation errors introduced by averaging non-linear
parameters, reconstructing the volume on a separate
system may help to flesh out these calculation problems.
unusual practices which could result in poor
measurement. The auditor’s report expresses any
restrictions or constraints in gathering or examining data.
Here, the auditor may note limitations placed on his
opinion by the scope. The report should also identify
areas for improvement and recommended corrective
action where necessary. If the auditor’s opinion is
adverse, he or she should provide remedies and the likely
results if problems are not addressed. The specific errors
found should be documented. If a payment adjustment is
recommended, it will include specific volume, energy or
monetary values. The reasoning behind the adjustment
should be sound and explained in detail, especially when
subject to interpretation. Any data to support the
adjustment should be included.
Alternatively, if the audit produced no substantial results,
there is still great value in knowing measurement
processes are producing good results. Either way, if the
opinion is not honored, the audit was of little value.

The Auditor’s Report

CONCLUSION
The word “audit” comes from the Latin root word
Audit resources, including the expertise of the auditor,
meaning “a hearing.” It is the same root word we use to
can be applied with various objectives and scopes to
get our words audible and auditorium. The idea is all of
capture the bulk of measurement errors and potential
the information is presented so everyone involved can
errors. Tests are administered, data is validated, and
hear and understand what has taken place. The auditor
information is examined from the regulations and
provides a bird’s-eye perspective to the story to help all
contracts to the final transaction records. Problems and
parties with this understanding.
errors encountered are documented in an auditor’s report,
with remedies and recommendations.
The audit culminates in an auditor’s report. This is the
main medium used for communicating the auditor’s story.
All sides to the stories of the transactions are heard and, if
It represents his or her comments and assertions
necessary, equitable adjustments can be made. The final
pertaining to the company’s, system’s, or station’s gas
result of this entire auditing process is an assurance of the
measurement. The auditor’s report consists of three main
integrity of an organization’s electronic gas measurement
sections: objective, scope and opinion.
business process.
The first two sections reiterate the objective and scope
API 21.1 is the backbone of the auditing process for
assignments of the auditor. Although the auditor may
electronic gas measurement. It provides the guidance
have clearly understood the objective and scope of the
necessary to ensure the integrity of electronic gas
audit, the documentation of these is still important for
measurement values. Its guidelines can be used to
other uses. For example, other interested parties may
develop an effective electronic gas measurement program.
desire to review the results of the audit. Before they can
API 21.1 helps the auditor to transform the complexity of
fully understand the auditor’s opinion, it is necessary for
electronic gas measurement into an effective means of
them to be able to gain an understanding of the objective
evaluating financial risk and financial opportunity.
and scope. Also, the audit may be reviewed again months
or even years later. Proper documentation of the
objective and scope help to recollect the intent of the
parties.

The section which contains the auditor’s opinion is what

most people think of when the term “auditor’s report” is
used. It may begin with a statement such as, “It is my
opinion…” and is just that; an opinion. However, it is an
expert’s opinion. The auditor’s opinion should indicate
whether the measurement processes comply with
contractual obligations and industry standards. The
auditor’s opinion should also draw attention to any